Doe v. Baram

Background

Jane Doe brought claims against Jonathan Baram and Warren & Baram Management LLC (WBM) under the Trafficking Victims Protection Reauthorization Act and various state laws. The court entered a default judgment against WBM after the company failed to obtain counsel and respond as required. The claims against Baram were later dismissed.

The case proceeded to an assessment of damages and other amounts owed after WBM’s default. Magistrate Judge Valerie Figueredo issued a report and recommendation on May 3, 2024. The recommendation proposed $1,000,000 in damages, consisting of $500,000 in compensatory damages and $500,000 in punitive damages, along with $142,570 in attorney’s fees and $774 in costs.

Objections and review

The parties had fourteen days to submit specific written objections. No objections were filed. Baram told the court that he had received the recommendation and wanted more time to review it, but he did not file objections or another extension request. WBM also had no attorney. The court explained that a corporation cannot represent itself in federal court and that Baram, as a person without a lawyer, could not represent WBM. The court therefore concluded that WBM had waived its right to object.

Because no timely objections were made, the court reviewed the recommendation for clear error rather than conducting a new review of disputed portions. The court stated that it independently reviewed the magistrate judge’s thorough report and found no error, clear or otherwise.

Ruling

Judge Ramos adopted the report and recommendation, including its recommendation regarding damages, attorney’s fees, and costs. The order directed the Clerk of Court to enter judgment and close the case. The opinion does not separately explain the legal basis for each underlying claim or provide additional analysis of the recommended damages beyond adopting the report.